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Covid-19 – Regulatory Statements and Information

The Pharmaceutical Society NI is working closely to with the Department of Health NI, the GPhC and other key stakeholders to ensure that we are taking appropriate regulatory actions to support pharmacists during this extremely difficult period, whilst also protecting the public and maintaining the continuity of the Pharmacy profession.

We have published the following statements and frequently asked questions which pharmacists and the public should read:

30 March - How will we approach Fitness to
Practise during the Covid-19 Pandemic?

During the ongoing pandemic emergency, our top priority in relation to Fitness to Practise is public protection and patient safety. We will continue to receive and log complaints and concerns, these will
be risk assessed and those which present an immediate risk to the public will be advanced if they meet the threshold for interim order. Other cases will be advanced should the risk assessment change or when the current emergency is over.

We will either hear or adjourn any cases currently listed and will list only the following type of case going forward:

1. Initial interim order applications
2. Interim order review hearings
3. High Court applications to extend interim orders
4. Substantive Fitness to Practise review hearings

All other face to face Statutory Committee hearings are being postponed and no new ones will be scheduled until further notice – this allows us to prioritise interim order and substantive order reviews.

In conjunction with the Chair of the Statutory Committee, we are considering arrangements to progress as many priority cases as possible by virtual hearings and case management reviews, and are also exploring the holding of some hearings on papers alone, with the agreement of the parties. We will communicate arrangements directly to the people involved in individual cases.

Joint Regulatory Statement

The UK Healthcare regulators released a recent statement on how we would regulate during the pandemic, which outlines that the current context will be taken into account provided registrants had followed standards and exercised their professional judgement. The statement is available on our website at : www.psni.org.uk/news/joint-regulators-statement-on-covid/

We are grateful for the understanding of all those involved in these processes during this time.

What will happen to existing
cases?

.
We are mindful that many of our registrants are heavily involved in the response to the Covid-19 pandemic or may be ill or having to self-isolate due to the virus. We do not wish to add unnecessarily to the pressure that pharmacists are under at this difficult time.

We must, however, continue to protect the public and maintain confidence in the pharmacy profession. In order to balance our public protection role and our understanding of the pressures facing the pharmacy profession, our fitness to practise focus for the foreseeable future will on those priority cases where the evidence we have indicates an immediate risk to patient and/or public safety, which may require an interim order application to be made. All other fitness to practise investigations will be suspended, unless a risk assessment suggests a change in their urgency, until the situation improves.

We will inform complainants and pharmacists involved in current investigations of this approach and support them where possible.

How will we handle new Complaints?

.
We will receive and document all new complaints about pharmacists, however, we will assess each complaint in relation to the potential risk to patients and the public. We will make interim order applications where we consider the evidence suggests there is an immediate risk to patient and/or public safety.

30 MarchOur approach to Fitness to Practise during the Covid-19 Pandemic

30 MarchJoint statement on Social Distancing in pharmacies.

30 March Personal Protective Equipment PPE Update to service

27 March – Frequently asked questions in relation to Covid-19

Questions from members of the
public
A pharmacy is inflating prices for non-medicine items such as hand sanitiser or masks. Is this a breach of your standards and will you investigate this pharmacy?
.
Profiteering during the current challenging situation by
inflating prices of shortage products risks bringing the profession into
disrepute. We are reminding pharmacy owners and pharmacy professionals that they need to continue meeting our standards at all times during the pandemic. We do however recognise that shortages can engender increases with suppliers and distributors of products – if you are concerned you should take the matter up with your pharmacy in the first instance.
Can the pharmacy give me advice and medicines to help me treat the symptoms of coronavirus?
.
Do not go into a pharmacy, GP or hospital if you or someone
you live with has coronavirus symptoms (high temperature or a new, continuous cough). You can ask someone else to collect your medicines for you, or order online. Read the Public Health Agency advice on what to do if you or a family member has symptoms of coronavirus.
A pharmacy is refusing to deliver my medicines to me, even though I need to self-isolate. What should I
do?
.
We understand the challenges you are facing in getting your
medicines while you self-isolate. We also recognise that pharmacies are working under significant pressure at the moment because of coronavirus and may not have enough capacity or resources to deliver medicines to everyone who is self-isolating. We would recommend you ask neighbours, friends or family if they would be able to collect your medicines on your behalf and then phone you
just before leaving them on the doorstep for you to collect.
Can I still make a complaint against a pharmacist during the Covid-19 pandemic?
.
Yes, we will receive and document all new complaints about
pharmacists, however, we will assess each complaint in relation to the
potential risk to patients and the public. The majority of complaints we will not actively investigate at this time, rather we will prioritise those cases that may impact on immediate patient safety, making interim order applications where we consider the evidence suggests there is an immediate risk to patient and/or public safety
Questions from pre-registration
trainees or tutors
What if I have to self-isolate or take sick leave during the coronavirus pandemic?
.
You must follow all government advice in relation to self-isolation. Do not go into your training site if you or someone you live with has symptoms of coronavirus for the period of isolation set out by the government.
For trainees: Do not worry if you need to take some days over the normal 42 days of permitted leave during your training because of the need to self-isolate. We will take a flexible and proportionate approach in these circumstances.
We ask that you contact us via email at pre-registration@psni.org.uk if you do exceed the total 42 day training absence limit . You do not need to contact us until you go over the 42 day limit.
If you are self-isolating but are otherwise well, we recommend that you use the time to progress what remaining aspects of training you have and avail of on-line resources such as those provided by NICPLD.
We can assure you that we are working through these issues as quickly as we can, with a view to facilitating the completion of the preregistration programme leading to registration, whilst acknowledging the exceptional and extremely difficult circumstances you are all working under.

Is the registration examination still going ahead?
.
We have made the decision to postpone the registration Exam in June and October. We will look to reschedule these assessments for a later date(s), either towards the end of this year or early in 2021, once the situation is clearer.
We are now working as quickly as possible to develop plans for the period between now and the rescheduled examinations, including the possibility of a form of provisional registration for current pre-registration trainees. We are carefully considering what options will be in the best interests of pre-registration trainees, pharmacy services and the general public, whilst protecting patient safety.
Please see our joint statement with the GPhC for further information: www.psni.org.uk/wp-content/uploads/2020/03/PSNI-GPhC-Joint-Statement-Pre-registration-Training-2020-26.03.20.pdf

What does the current situation mean for Pre-registration training requirements (Appraisals and portfolio)?
.
In relation to appraisals and portfolio aspects of training, and in line with the recent joint regulatory statement, we are encouraging tutors to use professional judgement to assess risks in the delivery of safe care, in the first instance, to prioritise patient care (informed by relevant guidance in the values and principles set out in the professional Standards) and similarly to make those professional judgements in relation to aspects of pre-registration training and assessment. We understand that at certain times many trainees will be required to work apart from their tutors and be unable to follow training plans. It is important that trainees are properly supported and supervised and working with pharmacist support and guidance. We know many will be approaching their next appraisal and will be receiving automatic prompts via the online portfolio, please be assured that we will take a pragmatic view on submission and ask that tutors and trainees do likewise, completing what can be completed in the circumstances.
During this difficult period, it will be essential that systems are in place so that trainee wellbeing is supported and that trainees are not operating outside their current competency.
We would assure tutors and trainees that we are working as quickly as we can to resolve these matters and aim to produce more detailed guidance as soon as we can.

Can I do my training online or remotely?
.
Please discuss this with your training provider and tutor- there may be parts of your training that can be done online. You can progress what remaining aspects of training you have and avail of on-line resources such as those provided by NICPLD.
.
Questions about the Covid-19
temporary register
How many people will join the Covid-19 temporary register?
.
At this stage, we are placing around 290 pharmacists in Northern Ireland onto the time-limited register, who have left the permanent register in good standing within the last 3 years. If an individual does not wish to be placed on the time-limited register, they are able to opt out.

Will all individuals previously on the register of pharmacists in Northern Ireland be placed on the Covid-19 temporary register?
.
No, at the moment only those who have left the register in good standing in the last three years are determined to be fit, proper and suitably experienced.
How was fit, proper and suitably experienced determined?
.
Council have agreed a policy that the test for fit, proper and suitably experienced, at this stage, relates to persons who left the register in good standing in the last three years – other applicants, who provide additional credentials including suitable qualifications, may join this register as long as the Registrar is satisfied that they are suitably experienced, fit and proper.
Do I have to join the Covid-19 temporary register if I do not want to?
.
No, should you not wish to be re-registered at this time please email registration@psni.org.uk with the words re-registration opt-out in the title of the email.
Do I need to pay to join the Covid-19 temporary register ?
.
No, you do not need to pay a registration fee to join the time-limited register.
What indemnity cover / insurance do I need to have to work?
.
Please speak to your employer about what arrangements will be in place for indemnity cover. Further information is available at www.npa.co.uk/insurance/professional-indemnity-insurance/locum-pharmacists/

Will any support be available to assist my return to practicing pharmacy?
.
Yes. The Northern Ireland Centre for Pharmacy Learning and Development has arranged an on-line resource to assist with return to practice. This is available at: www.nicpld.org/rp/
Where will I work?
.
The UCA has agreed to assist with placement – they can be contacted at natalie@uca.org.uk and further information may be found at www.uca.org.uk/sign-locum-membership . You may also choose to independently find employment.
What protection will I have from catching Covid-19 if I go to work?
.
Please follow the most recent government advice relating to keeping well during this period and discuss this with your employer.

What if I want to stay on the Covid-19 temporary register , but I'm worried about my own health and well-being?
.
You must give due consideration to your health and well-being before opting in to stay on the time-limited register and practice pharmacy. Please refer to the most recent government guidance when making your decision. Not all roles are patient facing. Depending on your skills, experience and location, you may be able to carry out roles that don’t involve face to face contact with patients. Please speak with your employer.

What information will a prospective employer ask for?
.
Before offering employment, your potential employer will ask for the following information:
• your Time-limited Registration number (which can be found on our website at www.psni.org.uk), a form of identification and proof of address
• the date you left the professional register of pharmaceutical chemists
• the area of pharmacy you practiced in
• your assessment of your level of competency
• to provide information relating to any health or conduct issues that might affect your fitness to practise
All employers have been written to and informed of this course of action and will be aware of the Covid-19 temporary register and who is on it. Employers will be asked to assure themselves that those individuals presenting for employment are those on the Covid-19 temporary register and that individuals are aware of no issues in relation to competency and health which might impair their fitness to practise.

What happens if someone raises a concern against me?
.
We will assess any concerns raised. The decision to remove someone from the Covid-19 temporary register rests with the Registrar of the Pharmaceutical Society.
The UK Healthcare regulators released a recent statement on how we would regulate during the pandemic, which is intended to reassure registrants that context would be taken into account provided registrants had followed standards and exercised their professional judgement. The statement is available on our website: www.psni.org.uk/news/joint-regulators-statement-on-covid-19/

Do I need to meet any CPD requirements to join the Covid-19 temporary register ?
.
No. Our normal registration and CPD requirements will not apply to those joining the Covid-19 temporary register.

Will my previous annotations on the register apply (SP/IP)?
.
No, your previous annotations on the register will not stand if you are on the Covid-19 temporary register.

What would happen to me if any questions were raised about my competency or fitness to practise, after I started work?
.
These would not be dealt with by way of any Fitness to Practise proceedings but where there were justifiable concerns the Registrar would have the power to remove you from the Covid-19 temporary register .

Why would the Registrar of the Pharmaceutical Society NI decide to remove me from the Covid-19 temporary register ?
.
If concerns are raised about an individual’s fitness to practise who is on the time-limited register, the Registrar has the power to remove them from the time-limited register immediately.
Questions from former registratants eligible for temporary registration
I'm a pharmacist who voluntarily removed myself from the register, or decided not to renew my registration. Can I re-join the register so that I can practise during the outbreak of COVID-19?
.

In an emergency, we have powers under the Coronavirus Bill 2020 to temporarily register fit, proper and suitably experienced people to act as pharmacists to help protect public health. Please contact registration@psni.org.uk with any queries.

Questions about CPD
Do I still need to complete my CPD during the coronavirus pandemic?
.

Pharmacists will not be required to submit the normally required CPD portfolios by 01 June 2020 and will be provided with two months’ notice of a new submission date later in 2020. The decision on setting a new submission date will be context specific and will be taken in consultation with the Department of Health NI. It is important that pharmacists maintain the necessary skills and knowledge to perform their role, we are not seeking documented proof of activity at this time

Does not being required to submit CPD by 01 June mean I can stop doing CPD?
.
No, this decision does not preclude pharmacists from doing CPD at a time when they may need to rapidly improve their skills but it removes the burden of writing it up on the online portal and submitting it by 01 June 2020. It is recommended that, where possible, pharmacists maintain their professional development activities and learning.
Will I have less time to complete my CPD in 2020/2021?
.
No, to accommodate this change for the 2019/20 CPD year, adjustments will be made to the requirements for the 2020/21 CPD year which will be shortened in length and the quantity adjusted accordingly. All pharmacists will be informed of the necessary changes in the 2020/21 CPD year when a submission date for the 2019/20 CPD year has been agreed.

27 March – Pre-registration Training and Covid-19

26 March – PSNI GPhC Joint Statement – Pre-registration Training 2020

25 March – Pre-registration Training and Covid-19

24 March – Covid-19 Temporary Register

Covid-19 Temporary Registration FAQs
How many people will join the time-limited register?
At this stage, we are placing around 300 pharmacists in Northern Ireland onto the time-limited register, who have left the permanent register within the last 3 years. If an individual does not wish to remain on the time-limited register, we will remove them.
Will all individuals previously on the register of pharmacists in Northern Ireland be placed on the time-limited register?
No, at the moment only open those who have left the register in good standing in the last three years and are determined to be fit and proper.
How was a fit and proper person determined?
Council have agreed a policy that the test for fit and proper, at this stage, relates to persons who left the register in good standing in the last three years – other applicants, who provide additional credentials including suitable qualifications, may join this register as long as the Registrar is satisfied that they are suitably experienced, fit and proper.
Do I have to join the time-limited register if I do not want to?
No, should you not wish to be re-registered at this time please email registration@psni.org.uk with the words re-registration opt-out in the title of the email.
Do I need to pay to join the time-limited register?
No, you do not need to pay a registration fee to join the time-limited register.
What indemnity cover / insurance do I need to have to work?
Please speak to your employer about what arrangements will be in place for indemnity cover.. Further information is available at www.npa.co.uk/insurance/professional-indemnity-insurance/locum-pharmacists/
Where will I work?
The Department of Health has arranged for the UCA Locum Agency to assist with the placement of pharmacists in Northern Ireland – they can be contacted at natalie@uca.org.uk. Further information may be found at www.uca.org.uk/sign-locum-membership
What protection will I have from catching Covid-19 if I go to work?
Please follow the most recent government advice relating to keeping well during this period and discuss this with your employer.
What if I want to stay on the time-limited register, but I'm worried about my own health and well-being?
You must give due consideration to your health and well-being before opting in to stay on the time-limited register and practice pharmacy. Please refer to the most recent government guidance when making your decision. Not all roles are patient facing. Depending on your skills, experience and location, you may be able to carry out roles that don’t involve face to face contact with patients. Please speak with your employer.
What information will a prospective employer ask for?
Before offering employment, your potential employer will ask for the following information:
• your Time-limited Registration number (which can be found on our website at www.psni.org.uk), a form of identification and proof of address
• the date you left the professional register of pharmaceutical chemists
• the area of pharmacy you practiced in
• your assessment of your level of competency
• to provide information relating to any health or conduct issues that might affect your fitness to practise
All employers have been written to and informed of this course of action and will be aware of the Time-limited Register and who is on it. Employers will be asked to assure themselves that those individuals presenting for employment are those on the Time-limited Register and that individuals are aware of no issues in relation to competency and health which might impair their fitness to practise.
What happens if someone raises a concern against me?
We will assess any concerns raised. The decision to remove someone from the time-limited register rests with the Registrar of the Pharmaceutical Society.
Do I need to meet any CPD requirements to join the time -limited register?
No. Our normal registration and CPD requirements will not apply to those joining the time-limited register.
Will my previous annotations on the register apply (SP/IP)?
No, your previous annotations on the register will not stand if you are on the time-limited register.
What would happen to me if any questions were raised about my competency or fitness to practise, after I started work?
These would not be dealt with by way of any Fitness to Practise proceedings but where there were justifiable concerns the Registrar would have the power to remove you from the time-limited register.
Why would the Registrar of the Pharmaceutical Society NI decide to remove me from the time-limited register?
If concerns are raised about an individual’s fitness to practise who is on the time-limited register, the Registrar has the power to remove them from the time-limited register immediately.

19 March 2020Postponement of 2020 CPD Submission

19 March 2020 FAQs – Postponement of 2020 CPD Submission

19 March 2020Coronavirus (Covid 19) and Pre-registration Training

19 March 2020Pre-registration Tutor Course 2020 – Postponement

18 March 2020Joint statement from the GPhC and the Pharmaceutical Society NI

03 March 2020 Joint regulators’ statement Covid19

Information Sources

Public Health Agency

Department of Health NI

Health and Social Care Board

World Health Organisation